IRS tackles exclusive provider arrangements and UBIT.
Jurisdiction | United States |
Author | Kautter, David J. |
Date | 01 January 2002 |
In an Aug. 14, 2001 field memorandum, the IRS discussed several scenarios in which exclusive provider arrangements might not give rise to unrelated business income tax (UBIT). An exclusive provider arrangement is an arrangement under which an exempt organization agrees that products or services that compete with the payor's products or services will not be sold or provided in connection with One or more of the organization's activities. The Service issued the memo because of an "incorrect...
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